Product Updates October 2025
The Product Updates for October 2025 from BankPolicies.com feature the following revised policy and form template products:
Artificial Intelligence Policy Template
Information Systems Security Policy Template
The update to these products is in response to the G7 Cyber Expert Group’s “G7 Cyber Expert Group Statement on Artificial Intelligence and Cybersecurity September 2025” dated 09/25/25 that outlines what policymakers and financial institutions should consider when weighing the potential cybersecurity benefits of artificial intelligence against misuse of the technology by malicious actors. AI technologies offer significant opportunities for financial institutions to enhance their risk management capabilities. However, it could also increase the frequency and impact of malicious cyber activity, according to the working group. The statement lists ways AI can enhance both cyber resilience and cyber risk. In addition, it lists key considerations for financial institutions and policymakers on managing AI-enabled risks.
Automated Clearing House Policy Template
The update to this product is in response to Nacha ACH Operations Bulletin #3-2025 entitled “ACH Operations #3-2025 – Automating the Request for Proof of Audit” dated 09/11/25 that informs banks and credit unions that starting next month, the process of requesting proof of an ACH rules compliance audit of the financial institution and, if applicable, its third-party senders, will be automated. The process will go through Nacha’s Risk Management Portal. This operations bulletin has no impact on corporate originators.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Notice FIN-2025-NTC2 entitled “FinCEN Notice on Financially Motivated Sextortion” dated 09/08/25 that assists financial institutions in identifying and reporting suspicious activity related to financially motivated sextortion, a disturbing and increasingly common typology that can devastate the lives and families of its victims. Financially motivated sextortion occurs when perpetrators, using fake personas, coerce victims to create and send sexually explicit images or videos of themselves, only to threaten to release the compromising material to the victims’ friends and family unless the victims provide payment. The perpetrators of financially motivated sextortion schemes can target anyone, with many victims being over the age of 18, according to law enforcement. However, minors (especially boys between the ages of 14 and 17) are a particularly vulnerable population and have been increasingly victimized in these schemes.
Information Systems Security Policy Template
The update to these products is in response to client requests that we provide a detailed reference to the NIST Cybersecurity Framework 2.0 which provides guidance to industry, government agencies, and other organizations to manage cybersecurity risks, and offers a taxonomy of high-level cybersecurity outcomes that can be used by any organization (regardless of its size, sector, or maturity) to better understand, assess, prioritize, and communicate its cybersecurity efforts.
Model Risk Management Program Policy Template
The update to this product is in response to OCC Bulletin 2025-26 entitled “Model Risk Management: Clarification for Community Banks” dated 10/06/25 that underscores flexibility for community banks to tailor their model risk management practices.
Non-Deposit Investment Products Policy Template
The update to this product is in response to OCC Bulletin 2025-25 entitled “Retail Non-Deposit Investment Products: Exam Procedures for Community Banks” dated 10/06/25 that states that the OCC will no longer examine community banks using the procedures and standards in the “Retail Nondeposit Investment Products” (RNDIP) booklet of the Comptroller’s Handbook. Community banks are still expected to follow all laws, rules, and regulations applicable to their RNDIP offerings and comply with all pertinent legal requirements.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation A: Extensions of Credit by Federal Reserve Banks” dated 10/02/25 that announced final amendments to its regulations to reflect the Federal Reserve Board’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of the Board’s primary credit rate action.
The amendments to part 201 (Regulation A) are effective 10/02/25. The rate changes for primary and secondary credit were applicable on 09/18/25.
The update to this product is in response to the CFPB’s Final Rule entitled “Small Business Lending Under the Equal Credit Opportunity Act (Regulation B); Extension of Compliance Dates” dated 10/02/25 that finalizes its June 18, 2025 interim final rule amending Regulation B to extend the compliance dates set forth in its 2023 small business lending rule, as amended by a 2024 interim final rule, and to make other date-related conforming adjustments. This final rule is effective December 1, 2025.
The update to this product is in response to the Federal Reserve’s Final Rule entitled “Regulation D: Reserve Requirements of Financial Institutions” dated 10/02/25 that announced final amendments to its regulations to revise the rate of interest paid on balances (“IORB”) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 4.15 percent, a 0.25 percentage point decrease from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee (“FOMC” or “Committee”).
The amendments to part 204 (Regulation D) are effective 10/02/25. The IORB rate change was applicable on 09/18/25.
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